EU Public consultations on Ecodesign and Energy labelling refrigerators, dishwashers, washing machines, televisions, computers and lamps Brussels, 13 th April 2018 Contact persons: Chloé Fayole, ECOS chloe.fayole@ecostandard.org Stéphane Arditi, EEB stephane.arditi@eeb.org The deadline for submitting your answer is 7 th May 2018. How do I do this? Follow this link: https://ec.europa.eu/eusurvey/runner/ecodesign- EnergyLabelling-5-priority-product-groups The questionnaire is available in all EU official languages. Choose your language from the drop-down menu at the top right side! You must fill in all fields marked with *! Use the default answers provided in this template. If you want to only answer the questions related to repair, then go directly to the text highlighted in yellow below. You can also pause at any time and continue later. Just go back to the top of the webpage and press the button Save as Draft at the top right side. Please note that you can skip all questions about which you do not feel comfortable or feel that you do not have sufficient information! Scroll down to the very end of the questionnaire and write in your further comments into the final text box. You have space for 3000 characters and we provided you with a standard statement that you should translate into your native language. Press on the Submit button at the bottom of the webpage. You are done!
PART 1: Information about the respondent Fill in your personal details PART 2: General background information * Is your professional activity related to products covered by ecodesign and energy labelling regulations? Fill in the answer that applies to your situation * Are you (or your members) aware of the ecodesign requirements for one or more of the product groups subject to this questionnaire? * Please specify for which product groups: Refrigerators, dishwashers, washing machines, televisions, computers and lamps * Are you (or your members) aware of the energy label for one or more of the product groups subject to this questionnaire? * Please specify for which product groups: Refrigerators, dishwashers, washing machines, televisions, computers and lamps In your, does the EU energy label help you (or your members) when deciding which product to buy? Should there be ecodesign requirements on reparability and durability for energy related products? 2
Should the energy label include information/symbols on reparability and durability? In relation to reparability, upgradeability and durability (overall referred to as "resource efficiency") how are the following criteria? Please rate the level of importance for each criterion Don't not somewhat very know Accessibility of components Availability of spare parts Delivery time for spare parts Complete manual for reparability and maintenance with diagrams and list of spare parts Other: Please specify: (200 character(s) maximum) Easy and open access to repair documents and tools Affordable spare parts and repair services Availability of software and firmware updates Modularity of products, standardised interface and cross-compatibility between different brands If you needed additional technical information about a product, where would you look? at least 1 choice(s) Manufacturer's website Retailer's website Product information sheet Booklet of instructions User forums on the internet Consumer organisations Other Please specify: (200 character(s) maximum) Booklet of instruction should be available in paper and easily accessible on the manufacturers website 3
PART 3: Questions for SMEs only You can skip this part if you are not owning or working in a small or medium sized company dealing with product manufacturing, servicing or repairing. PART 4: Technical background information A. This section asks specific questions on household refrigerators and freezers Should wine storage appliances be covered by the definition of a household refrigerating appliance or should they be a separate class?, they should be covered by the definition of a household refrigerating appliance, they should be a separate class Should low noise refrigerating appliance be covered by the definition of a household refrigerating appliance or should they be a separate class?, they should be covered by the definition of a household refrigerating appliance, they should be a separate class Should different types of appliances be treated differently in the energy efficiency calculations? Appliances with different defrost technologies? Appliances that are built-in versus standalone? Appliances that combine different compartments (e.g. a fridge freezer combination)? Appliances that help prevent foodwaste versus normal appliances? for ecodesign, for energy label for ecodesign, for energy label Don't know Should refrigerating appliances with a glass door (for example, mini-bars and wine storage appliances) be in the scope of the regulation for household fridges or in the scope of a separate regulation for commercial refrigerating appliances? They should be in the scope of the regulation for household fridges They should be in the scope of the regulation for commercial refrigerating appliances 4
B. This section asks specific questions on household dishwashers Did you know that minimum cleaning performance requirements exist for dishwashers and that pre-rinsing dishes is therefore not necessary? Do you know that longer dishwashing programmes tend to use less energy than shorter programmes?, I am already aware, I am not aware Should information regarding the combination of time and energy consumption be made available to end-users? If your dishwasher broke down, what would you need to have it repaired? not somewhat very Don't know A warranty (guarantee) A list of certified repairers Quick repair time Spare parts and instructions so I could repair it myself Detailed quotation for a complete repair A post-repair warranty (guarantee) if the product's original warranty has expired Other: Please specify: 200 character(s) maximum Affordable spare parts, instructions and repair tools should also be available to independent repairers The list of repairers should include all repairers, certified and independent 5
How long would you expect spare parts to be available for your dishwasher? 2 years or less Between 2 and 5 years Between 5 and 10 years More than 10 years In order to evaluate product performance, how are the following testing programme characteristics? Please rate the importance that you would give to including the following programme: Most frequentlyused programmes (e.g. Ecoprogramme, normal programme, etc Most energy intensive programmes (e.g. pots and pans, heavy-duty cycles, etc.) Low power modes (e.g. left-on mode, left-off mode or delayed start mode) Programme duration (for all programmes) not somewhat very Don't know or no If the parameters listed below were included in the EU Energy Label on household dishwashers, which ones would you find useful? Tick all that apply: at least 1 choice(s) Capacity (amount of plates, glasses, etc.) Energy efficiency Energy consumption Water consumption Combined cleaning and drying performance ise emissions Other: repairability index, free warranty periods 6
C. This section asks specific questions on household washing machines and washer-dryers Do you know that longer programmes tend to have higher energy savings?, I am already aware, I am not aware Should information regarding the combination of time and energy consumption be included in the EU Energy Label? Should information regarding the combination of time and energy consumption be made more clearly visible on the household washing machines and the washer-dryers? If your household washing machine or washer-dryer broke down, what would you need to have it repaired? not somewhat very Don't know A warranty (guarantee) A list of certified repairers Quick repair time Spare parts and instructions so I could repair it myself Detailed quotation for a complete repair A post-repair warranty (guarantee) if the product's original warranty has expired Other: Please specify: 200 character(s) maximum 7
Affordable spare parts, instructions and repair tools should also be available to independent repairers The list of repairers should include all repairers, certified and independent How long would you expect spare parts to be available for your household washing machine or washer-dryer? 2 years or less Between 2 and 5 years Between 5 and 10 years More than 10 years In order to evaluate product performance, how are the following testing programme characteristics? Please rate the importance that you would give to the following characteristics: Most frequently-used programmes (e.g. cotton 40oC programme, cold programme, etc.) Most energy-intensive programmes (e.g. cotton 90oC programme, etc.) Low power modes (e.g. left-on mode, left-off mode or delayed start mode) Programme duration (for all programmes) not somewhat very Don't know If the criteria listed below were to be included in the EU Energy Label, which of the following criteria would you find useful? at least 1 choice(s) Energy efficiency Energy consumption Water consumption Capacity Washing performance ise Spin-cycle efficiency Other: repairability index, free warranty periods 8
D. This section asks specific questions on electric lamps and luminaires Should the ecodesign requirements be updated to take into account emerging high-efficient technologies, notably LEDs? Should the ecodesign requirements take into account visual effects such as flicker? Are you in favour of products containing a light source that cannot be removed or replaced (e.g. a sealed luminaire)?, I like them. In this way I can buy frequently a new luminaire and change the appearance in my room, but only when they are cheap, I want to be able to change or replace the light source (e.g. the light bulb) The label on luminaires should: Be kept as it is today Be replaced by a label that concerns only the light source which is contained in the luminaire Be discontinued What information would you like to have when you buy a lamp/light bulb: Don't know or no Quantity of light provided by the lamp (expressed in Lumen)? Energy efficiency expressed in terms of lumen per watt? Warm/cold effect of LEDs? Life-time? Watt equivalence with old bulbs (incandescents)? If it is tested for flickering? Other: Please specify: 200 character(s) maximum Declared lifetime and switching cycle values 9
E. This section asks specific questions on electronic displays (computer monitors and televisions) A new standard for improving image quality is HDR (High Dynamic Range). A display may even double its power use when displaying content filmed and broadcast in HDR. Would the indication of the power consumption in HDR mode be a relevant information for your purchase choice?, I want a clear indication of it and distinct from power consumption in normal mode, I find confusing too many values indicated The current energy label for televisions indicates the "annual" energy consumption of the television. What assumptions should be used if the same indication will be provided in the new label (for televisions, computer monitors or other displays)? An indication would not make sense, given that usage patterns differ too much 4 hours on, 7 days a week 8 hours on, 5 days a week 10 hours on, 7 days a week Other: One of the components more likely to fail in electronic products is the power supply (e.g. because of electric surges). Would you prefer a display with a standardised external power supply (as a USB with type-c connector) that you could easily buy and replace yourself?, I would prefer a display with such a feature and using a charger that I have or buy separately, such a feature would be irrelevant in my purchase decision What information would you like to have clearly provided when you buy an electronic display (television, computer display or similar)? Measured average power used when "on" in normal mode (Watt) Measured average power used when "on" in HDR mode (Watt) Diagonal size (cm/inches) Resolution (horizontal x vertical) in pixels Nickname of the resolution level (e.g. UHD, WQHD, ) The power supply is external and standardised (e.g. USB Type-C) Presence of a TV tuner (i.e. to distinguish a TV from another display) Presence of a processor (i.e. to distinguish a smart TV) Network interfaces (i.e. WiFi, RJ45, etc.) not somewhat very Don't know 10
F. This section asks specific questions on computers Would information about the energy efficiency of a computer be a useful indicator to help determine your purchase choice?, it would help to easily compare different models Would a "smart function", to help improve the battery durability in a laptop, be relevant to you?, it would be useful to limit the charge level when keeping the device regularly connected to the mains, I always want the battery fully charged In your purchase choice of a computer is the expandability relevant? Crucial Important, if it compromises lightness, sturdiness or other features Don't know or no Main memory Storage (hard disk, SSD) In your purchase choice of a computer, how is: Important t crucial for my choice, unless this feature comes at no extra cost Don't know battery durability a standard external power supply (as a USB with type-c connector) for various electronic devices and keep it when replacing the computer sturdiness (e.g. resistance to shocks and falling on the ground) waterproofness (i.e. damage from a drink reversed on the laptop is limited to the keyboard) a "reset to factory settings" function, physically and securely erasing any personal data (to donate or resell the device) Further comments. Are there further comments you would like to make on anything that is not covered above? 3000 character(s) maximum 11
If you would like your answer to cover both energy efficiency and resource aspects: The implementation of the Ecodesign & Energy Labelling policies during the mandate of EU President Juncker has been characterised by continuous delays and a historically low number of measures adopted. The expected package of measures is a golden opportunity for the Commission to finalise long-started work and therefore we call on the European institutions to adopt a package of measures which is as ambitious and comprehensive as possible. It is time for Europe to take full advantage of all the benefits that Ecodesign and Energy Labelling policies can bring. This package of measures also offers a great opportunity to take ambitious actions with regards to resource efficiency, by encouraging the durability, repairability and recyclability of products. This is an approach which we strongly support and call on the European institutions to safeguard the proposed requirements and to even go beyond them. We have listed below the requirements we would like to see immediately included / safeguarded in the proposals: - For dishwashers and washing machines, we support the availability of spare parts during the lifetime of the product, including a maximum delivery time; unrestricted independent operator access to information and tools needed for repair; possibility to disassemble key components; indication of free warranty time on the Energy Label. - For refrigerators, we welcome the provision on the availability of spare door gaskets - although the duration of 10 years appears insufficient - and think that the Commission should integrate additional repair and recycling requirements in line with the dishwashers and washing machines proposals. - With regards to lighting, we strongly support the efforts made by the Commission on the removability of light sources and control gears and think the Commission should go even further by making the components of these luminaires replaceable. We call on the Commission to reintroduce the minimum lifetime requirements for light sources as well as the information requirements on the number of switching cycles and declared lifetime. - For displays and servers, we strongly support the proposed provision on removability of integrated displays, as well as the other resource efficiency requirements, notably regarding the non-destructive disassembly of key components. - With regards to computers, we would like to mention here that we have rated waterproofness as in our answers to the questionnaire, provided that it does not impair easy repair and upgradability. If you would like your answer to cover only the repair aspects: Manufacturers should be legally obliged to share repair information and instructions so that consumers know if a product is repairable before purchasing it. Consumers must then have the right to decide who should repair the things they own. Local repair shops may offer a cheaper and quicker fix compared to original manufacturers, but consumers are currently prevented from acting in their own interests because many manufacturers do not fully support independent repair shops with the necessary information, software/firmware and tools. Mandatory design requirements must ensure that the key components of a product are easily accessible so that they can be replaced if they break. Spare parts and repair tools should become widely available at reasonable costs and for an appropriate period of time. Moreover, the work of repairers would be easier if different manufacturers designed key components in a standardised way (e.g. interchangeable washing machine motors across different brands). Similarly, manufacturers should make software updates available so that products such as home appliances, computers and televisions can be upgraded rather than replaced with new hardware. Timing is critical. Any further delay in the implementation of repair rules would be a missed opportunity for consumers and the planet. w it s time for the EU to deliver on its promise to accelerate the transition to a circular economy through better eco-design and repair. 12